Case law

Barone v. Commissioner

85 T.C. 462 · United States Tax Court · Sep 17, 1985

Brandl v. Commissioner, supra; Kroll v. Commissioner, supra. … Sapson v. Commissioner, supra.

Matheson Co. v. Commissioner

16 T.C. 478 · United States Tax Court · Feb 28, 1951

The Matheson Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Matheson Co. v. Commissioner Docket No. 10619 United States Tax Court 16 T.C. 478 ; 1951 U.S. Tax Ct. … Lucas v. Ox Fibre Brush Co ., 281 U.S. 115 . The record here is entirely too indefinite to say that Florence H. Matheson did not earn the payments made to her.

Delvecchio v. Comm'r

81 T.C.M. 1712 · United States Tax Court · Jun 6, 2001

See Recklitis v. Commissioner, supra at 909; Meier v. Commissioner, 91 T.C. 273, 297 (1988). … Stoltzfus v. United States, 398 F.2d 1002, 1004 (3d Cir. 1968); Parks v. Commissioner, 94 T.C. 654, 660-661 (1990). Fraud will never be presumed, Beaver v.

Rocky Mountain Drilling Co. v. Commissioner

25 T.C. 1195 · United States Tax Court · Mar 9, 1956

Rocky Mountain Drilling Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Rocky Mountain Drilling Co. v. Commissioner Docket No. 37463 United States Tax Court 25 T.C. 1195 ; 1956 U.S. Tax Ct. … Not having assented to the same I hereby protest any personal liability should any action later arise against the members of the Board of Directors of your Company."

Lippman v. Commissioner

52 T.C. 135 · United States Tax Court · Apr 22, 1969

In order to meet this condition, the board of trustees of Lakeside met on May 16, 1962, and unanimously passed a resolution which called for the assessment of a fee from each member of the staff as a condition to remaining … Gilman, 18 B.T.A. 1277 (1930), affd. 53 F. 2d 47 (C.A.8, 1931), and Bercaw v. Commissioner, 165 F. 2d 521 (C.A.4, 1948), affirming a Memorandum Opinion of this Court.

Holloway v. Commissioner

10 T.C. 828 · United States Tax Court · May 13, 1948

Holloway, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent Holloway v. Commissioner Docket No. 11427 United States Tax Court 10 T.C. 828 ; 1948 U.S. Tax Ct. … The decedent's wife boarded and cooked for the men. Occasionally, when the demand arose, decedent would hire, as extra help on their days off, some of the men working at the oil fields.

McCue v. Commissioner

1 T.C. 986 · United States Tax Court · Apr 20, 1943

Nolan, Deceased, Petitioner, v. Commissioner of Internal Revenue, Respondent McCue v. Commissioner Docket No. 308 United States Tax Court 1 T.C. 986 ; 1943 U.S. Tax Ct. … It provides, in part: If the Commissioner has mailed to the taxpayer notice of a deficiency as provided in subsection (a) of this section, and the taxpayer files a petition with the Board within the time prescribed in such

Tecumseh Corrugated Box Co. v. Commissioner

94 T.C. 360 · United States Tax Court · Mar 12, 1990

Similarly, in Maixner v. … In Fireoved v.

Martin Timber Co. v. Commissioner

31 T.C.M. 1266 · United States Tax Court · Dec 27, 1972

MARTIN TIMBER Co., INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Martin Timber Co. v. Commissioner Docket No. 487-71. United States Tax Court T.C. Memo 1972-255 ; 1972 Tax Ct. Memo LEXIS 2 ; 31 T.C.M. … $49 per thousand board feet, and the fair market value of the hardwood on that date was $27 per thousand board feet.

A. Finkl & Sons Co. v. Commissioner

38 T.C. 886 · United States Tax Court · Sep 19, 1962

Finkl & Sons Company, Petitioner, v. Commissioner of Internal Revenue, Respondent A. Finkl & Sons Co. v. Commissioner Docket No. 44728 United States Tax Court 38 T.C. 886 ; 1962 U.S. Tax Ct. … Brown Paper Mill Co ., 23 T.C. 47 ; Industrial Yarn Corporation , 16 T.C. 681 ; Bulletin on Section 722 , p. 17.

H Enters. Int'l v. Commissioner

75 T.C.M. 1948 · United States Tax Court · Mar 9, 1998

See generally Leslie v. … See Indian Trail Trading Post, Inc. v. Commissioner, supra at 501. V.

Mogab v. Commissioner

70 T.C. 208 · United States Tax Court · May 15, 1978

Godart v. … See Spiegel v. Commissioner, 49 T.C. 527, 532 (1968). There is no indication in the record before us that London or its board of directors adopted the contents of the solicitation letters.

Iversen v. Commissioner

3 T.C. 756 · United States Tax Court · May 9, 1944

S. 112 ; Helvering v. Eubank, 311 U. S. 122 , and Harrison v. Schaffner, 312 U. … The retention by the grantor of the power to control the disbursements of the trust fund was considered sufiicient to justify taxing the income to him under section 22 (a) in Brown v. Commissioner, 131 Fed. (2d) 640.

Phillips v. Commissioner

17 T.C. 1027 · United States Tax Court · Dec 20, 1951

Phillips, Petitioner, v. Commissioner of Internal Revenue, Respondent. Howard Phillips, Petitioner, v. Commissioner of Internal Revenue, Respondent. Della Phillips, Petitioner, v. … It placed the retained portions in a reserve and issued to the petitioners non-interest-bearing, nonnegotiable, nonassignable revolving fund certificates payable only at the discretion of the Board of Directors, to evidence

Estate of Capell v. Commissioner

36 T.C.M. 1673 · United States Tax Court · Nov 30, 1977

Brown v. Commissioner, supra, 54 T.C. at 1487 and 1490 ; Browne v. United States, 356 F. 2d 546 (Ct. Cl.). … Brown, supra, 54 T.C. at 1488 . See also Turner v. Commissioner, T.C.

Buckley v. Commissioner

22 T.C. 1312 · United States Tax Court · Sep 30, 1954

The so-called document of constitution or charter as well as the bylaws of each company provided for centralized management in its officers and board of directors. … See also Commissioner v. Nebo Oil Co., Trust, 126 F. 2d 148 .

Spaulding Bakeries, Inc. v. Commissioner

27 T.C. 684 · United States Tax Court · Jan 18, 1957

Spaulding Bakeries Incorporated, Petitioner, v. Commissioner of Internal Revenue, Respondent Spaulding Bakeries, Inc. v. Commissioner Docket No. 55543 United States Tax Court 27 T.C. 684 ; 1957 U.S. Tax Ct. … See Cortland Specialty Co. v. Commissioner , 60 F. 2d 937 , 939-940 , (C. A. 2), certiorari denied 288 U.S. 599 ; Helvering v. Credit Alliance Corporation , 316 U.S. 107 , 112 .

Bryant Trust v. Commissioner

11 T.C. 374 · United States Tax Court · Sep 27, 1948

A. 1121, the Board of Tax Appeals was of the same opinion. … Louis Railway Co. v. Backus, 154 U.

Wolfe v. Commissioner

8 T.C. 689 · United States Tax Court · Mar 31, 1947

In Ware v. … C. 582 ; Hubbell v. Commissioner , 150 Fed. (2d) 516 ; Oberwinder v. Commissioner , 147 Fed. (2d) 255 ; Robert P. Hackett , 5 T. C. 1325 , and Ward v.

Estate of Morse v. Commissioner

17 T.C.M. 261 · United States Tax Court · Mar 31, 1958

Morse v. Commissioner. Claribel K. Morse v. Commissioner. Estate of Morse v. Commissioner Docket Nos. 62902, 62903. United States Tax Court T.C. Memo 1958-51 ; 1958 Tax Ct. Memo LEXIS 181 ; 17 T.C.M. (CCH) 261 ; T.C.M. … At a meeting of the board of directors held on April 28, 1952, Claribel was elected president effective May 1, 1952.